Ethical Considerations for Public Private Partnerships
Public-private partnerships allow CDC to do more, faster. For more than a half century, CDC has been a leader in scientific research committed to protect the American people and keep Americans healthy, safe and secure. Our highest priority is to save lives and protect people.
The agency’s pledge to the American people includes being a diligent steward of the funds entrusted to it. Before accepting outside donations, we take a hard, close look to ensure that proper policies and guidelines are followed. Public-private partnerships help federal agencies do more with less, build on the capabilities of others, leverage collective action, improve performance, and realize cost savings.
We continually work to protect our scientific and programmatic integrity, maintain accountability, and find solutions to our nation’s most pressing problems. We recognize the value of open discussion and stay committed to improving our processes of ethical protections. CDC’s highest priority is to keep people safe. We leverage our medical and scientific expertise and our partnerships to diffuse health threats and make our country and our world a better place to live.
CDC’s conflict of interest review process:
CDC’s goal is to have a process that is sound, transparent, and aligns with CDC’s policies and our responsibility to be good stewards of the work we have been entrusted to perform.
CDC’s gift acceptance policy requires a review for conflicts of interest (COI) prior to accepting a gift. CDC updated the process to review and document the results of the COI review for gifts received from the CDC Foundation. The enhanced process went into effect on May 1, 2014. In April, 2015 that process was expanded to cover all gifts to CDC, not just those donated through the CDC Foundation.
The conflict of interest review process begins when a potential donor notifies CDC of their interest in giving a gift. The CDC principal investigator completes a Proposed Gift Background Information Form for each donor proposing a gift. A completed form is required for every gift even when a donor has previously been found to have no conflict associated with a different project. In other words the review is case by case – no donor can be found to be “grandfathered” in as a donor with no conflicts.
Determination of when a conflict of interest exists is the responsibility of a CDC Conflict of Interest (COI) Review Panel. The completed Gift Background Information Form is submitted to the Chair of the COI Review Panel to be placed on the monthly panel agenda. The panel consists of members from the Office of Scientific Integrity, Office of the General Counsel, CDC/Washington, Office of the Chief of Staff, and Office of the Chief Financial Officer. During the panel discussion, the Principal Investigator presents to the panel during an open session in which the panel can ask questions and seek clarification. Following the open session, a closed session is held for panel deliberation/decisions.
Final decisions regarding acceptance/rejection of gifts is made via consensus of panel members. In the event that consensus cannot be reached, input is sought from senior leaders in the Office of the Director, including the Director. The Principal Investigator is informed of the disposition of the proposed gift following the panel meeting. The panel Chair informs the Principal Investigator of the decision using the “COI Review Disposition Memo," and retains the records of all panel decisions.
Continuous Improvement:
In April 2015, CDC’s Advisory Committee to the Director (ACD) agreed to establish a workgroup of external advisors to review current practices in other organizations as well as CDC’s policies and procedures, and provide recommendations to the ACD for consideration to further improve our conflict of interest policies and procedures.
- Page last reviewed: May 22, 2015
- Page last updated: May 22, 2015
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